PwC has a dedicated Like Kind Exchange tax practice that has implemented over 50 LKE programs over the past eleven years.

• The PwC system has been developed and enhanced over the last five years and represents the best practices of our 50 implementations. We have grown our practice every year and invest significant amounts in our technology and our staff.
• Our application is highly scalable. We process more than 30 million transactions per month for our clients.
• The PwC LKE practice consists of more than 45 dedicated tax and technology professionals.

• As a Big Four firm, PwC has the necessary resources to keep the LKE system current with evolving tax developments. As part of our service offering, we notify clients of emerging and enacted tax positions that can impact their LKE programs.
• PwC provides system updates and functionality as part of our maintenance agreement with our clients. If a tax law change occurs, our clients receive the updated tax law changes -- including extensive testing by PwC tax professionals -- at no additional development charge.
• PwC will issue a tax opinion for the LKE program regarding its compliance with current tax rules and IRS guidance and can provide assistance in the event of an audit by taxing authorities. QI's generally will not provide tax advice.

• Trained tax and technology implementation resources will be on site to oversee program implementation in a manner consistent with your business needs and in compliance with tax safe harbors.
• Having a single vendor eliminates finger pointing among multiple service providers
• Our ASP approach to delivering LKE avoids the "It's a hardware problem, no it's a software problem" issue when installing in house. The ASP approach also allows PwC to significantly enhance our support capabilities.
• Our implementation approach is based on best practices and extensive knowledge of client processes.
• We will work with you or your outside accountant so that the original system configuration agrees to prior year tax positions and elections.

• Many implementations are completed in 12 to 16 weeks.
• PwC is able to deliver an automated and paperless LKE solution in a time efficient and cost effective manner.

"We conducted an extensive RFP process and spent considerable time with several potential providers and consulted their references. Ultimately, the outstanding tax technical expertise in LKE and extensive practical experience with large automotive fleet LKE programs were the deciding factors in selecting PwC. This was a significant undertaking for us and it was important to have someone with extensive, real-world experience. They brought a real "can-do" attitude and offered practical solutions to implementing LKE in our business."

- Jim Ryan, Dollar Thrifty Automotive Group, Inc.

PwC has developed technology that enables a completely paperless Like Kind Exchange process that conforms to current tax guidance.

• No paper based or manual interaction required with the QI
• All key LKE management functions are fully automated; including:
  • Matching
  • Identification
  • QI communications
  • Cash management
  • Tax accounting and reporting

• Equipment sales proceeds can be used to pay down credit arrangements or purchase new property. This approach can significantly reduce the funds held by the QI
• Methods have been developed for dealing with the difficulty in determining if property will be sold as inventory or rented at the time it is acquired. This initial designation is important, as inappropriate designation of purchases as rental property that is eventually sold as inventory can disqualify an entire LKE program.
• Pass-through data fields facilitate deferred tax accounting and return preparation.
• A complete audit trail tracks asset activity, facilitate program management, and provides for historical reporting based on the data as it existed at the designated time period.
• Asset attachments are handled automatically.

The role of the QI is to merely act as custodian for the exchange funds. If properly structured little QI interaction is required.

• Appropriately utilizing the QI does not guarantee that all tax requirements are met and tax benefits will be sustained on review by taxing authorities. PwC's tax advisors stay current with your evolving business activity and related LKE needs.
• An outside financial institution is generally used by other QI's to hold exchange funds; this necessitates interaction with three parties: the tax provider, the system provider and the depository institution. Our model requires interaction with only two parties: PwC and the depository institution.
• Separation of responsibilities between LKE service provider and QI enhances internal control and allows for continuation of your LKE program in the event that your LKE provider or QI exits the business or becomes insolvent.

• PwC has been in the LKE business for over fourteen years. We have invested considerable resources in our technology and in LKE specific training for our dedicated staff.
• PwC can leverage the full resources of our firm to implement changes to our service offering that may be required due to changes in tax law or QI procedures. We are not dependent on outside funds for investment.
• PwC has a considerable investment in many of our clients separate and apart from our LKE service offerings. That has and always will drive PwC to meet or exceed our client's expectations.